FIRST INFORMATION REPORT
CIPA RI 1100 (Under section 154 Cr. P.C.)
1. District- SOUTH-WEST DELHI P.S.: Binda Pur Year- 2013 FIR
No.588 Dated- 22.11.2013
2. Act(s): Section (s)
(i) IPC 1860 323/354/509
(ii) PROTECTION OF CIVIL RIGHTS ACT, 1955 3
(iii)
(iv)
3. Occurrence of offence:
(a) Day: Wednesday Date from: 25.09.2013 Date to:25.09.2013
Time Period: Time from: 06:30 hrs. Time to:
(b) Information received at PS: Date-22.11.2013 Time- 10:35 hrs.
(c) General Diary Reference Entry No. 15A Time- 01.35 hrs.
4. Type of Information: WRITTEN
5. Place of Occurrence:
(a) Direction and distance from PS:North-West/3.0 Km. Beat No.9
(b) Address: SHIV MANDIR PH-3, SEC-3, J.J. COLONY,
DWARKA, NEW DELHI, BINDAPUR
(c) In case, outside the limit of this Police Station:
Name of P.S.
5. Complainant/informant
a. Name: SANGEETA (W/O) GYANANDER
b. Birth Year : Nationality: INDIAN
c. Passport No. Date of Issue: Place of Issue:
d. Occupation:
e. Address: B-118 SE-3, JJ COLONY, DWARKA, NEW DELHI
7 Detail of known/ suspected /unknown accused, with full
particulars: (attached separate sheet if necessary)
(i) RAJ KUMAR (S/O) LATE AMAN SINGH
R/O X [Link]. 167, DHAKKA VILLAGE, DELHI
(ii) RAJ RANI (W/O) RAJ KUMAR
R/O X [Link]. 167, DHAKKA VILLAGE, DELHI
(iii)
8. Reasons for delay in reporting by the complainant/Informant. NO
DELAY
9. Particulars of properties stolen/involved (attach separate sheet if
necessary)
Sl. No. Property Type (Description) est. Values (Rs.)
status
(i)
(ii)
(iii)
10. Total value of property stolen
11. Inquest Report/U.D. case No., if any:
12.F.I.R. Contents (attach separate sheet, if
required): I, Sangeeta Verma W/o Gyanander
Verma R/o B-118, Sec-3, Phase-III, J.J.
Colony, Dwarka, New Delhi age 36 years old
[Link]. 9971010508 stated that I am living
on above stated address with my family and
I am a house wife. When today early in the
morning want to Shiv Temple for worship
and started worship then Chander Prakash
who also lives in our colony came there at
the time and started using abusing
language for me and said that this temple
is out (Brahmins). You belongs to Chude
chamar community and said how dare you to
enter in the temple. C.P. Pandey hold my
hair and evicted me in scrawling way from
the temple and he torn my suite and said
that she is prostitute and I will naked
her. [Link] threatened me that if you
will complain against them I will kill you
and your family. I am in fear that
[Link] and his relatives came any
threatened
13. Action taken since the above report
records commission of offence (s) U/s as
mentioned as item No.2.
i. Registered the case and took up the
investigation or.
ii. Directed/entrusted (Name of I.O.) Subhash
Chand Rank
No. 16080390 to take up the investigation
OR
iii. Refused investigation due to. OR
iv. Transferred to P.S. District
On point of jurisdiction.
F.I.R. Record over to the complainant/
informant, admitted to be correctly
records and copy given to this
complainant/informant free of cost.
R.O.A.C. Signature of officer
Name
Rank
14. Signature/Thumb impression of the
complainant/informant.
15. Date and time of dispatch to Court by DAK.
Any other or further relief/directions
which this Hon’ble Court may deem fit and
proper in the facts and circumstances of
the case in favour of the petitioner, in
the interest of justice.
PETITIONER
THROUGH
DELHI
DATED:
COUNSEL
PAWAN SHARMA & ASSOCIATES
ADVOCATES
CH. NO. 492A, WESTERN WING,
TIS HAZARI COURTS, DELHI-54
are accepted by me as true and correct
and the same are not being reproduced
here for the sake brevity and the same
may please be read as an integral part of
this affidavit.
3. That the petitioner has not filed any
other petition either before this Hon’ble
Court or before the Hon’ble Supreme Court
of India for grant of same or similar
relief.
DEPONENT
VERIFICATION:-
Verified at Delhi on 2016, that the
contents of my above affidavit are true
and correct to the best of my knowledge
and belief and nothing has been concealed
therefrom.
DEPONENT
Any other or further relief/directions
which this Hon’ble Court may deem fit and
proper in the facts and circumstances of
the case in favour of the applicant/
petitioner, in the interest of justice.
APPLICANT/PETITIONER
DELHI
DATED:
THROUGH
PAWAN SHARMA & ASSOCIATES
ADVOCATES
CH. NO. 492A, WESTERN WING,
TIS HAZARI COURTS, DELHI-54
are accepted by me as true and correct
and the same are not being reproduced
here for the sake brevity and the same
may please be read as an integral part of
this affidavit.
DEPONENT
VERIFICATION:-
Verified at Delhi on 2016, that the
contents of my above affidavit are true
and correct to the best of my knowledge
and belief and nothing has been concealed
therefrom.
DEPONENT
IN THE HON’BLE HIGH COURT OF DELHI AT NEW DELHI
BAIL APPLICATION NO.__________OF 2014
IN THE MATTER OF:
RAJ RANI ...PETITIONER
VERSUS
THE STATE ... RESPONDENT
MEMO OF PARTIES
RAJ RANI
W/o SH. RAJ KUMAR @ RAJU
R/O R/O [Link]. 375, PRITAM NAGAR,
NEAR TAGORE MODEL SCHOOL,
LUDHIANA, (PUNJAB)
...PETITIONER
VERSUS
THE STATE
GOVT. N.C.T. OF DELHI
...RESPONDENT
PETITIONER
DELHI
DATED: .01.2014
PAWAN SHARMA & ASSOCIATES
ADVOCATES
CH. NO. 492A, WESTERN WING,
TIS HAZARI COURTS, DELHI-54
IN THE HON’BLE HIGH COURT OF DELHI AT NEW DELHI
BAIL APPLICATION NO.__________OF 2014
IN THE MATTER OF:
RAJ RANI ...PETITIONER
VERSUS
THE STATE ... RESPONDENT
URGENT APPLICATION
TO,
THE REGISTRAR,
DELHI HIGH COURT
NEW DELHI
Sir,
Would your honour may be pleased to
treat the accompanying petition as urgent
one, the ground of urgency are:-
“That the petitioner is apprehending
arrest at any moment by the police”.
PETITIONER
DELHI
DATED: .01.2014
PAWAN SHARMA & ASSOCIATES
ADVOCATES
CH. NO. 492A, WESTERN WING,
TIS HAZARI COURTS, DELHI-54
IN THE HON’BLE HIGH COURT OF DELHI AT NEW DELHI
BAIL APPLICATION NO.__________OF 2014
IN THE MATTER OF:-
RAJ RANI ...PETITIONER
VERSUS
THE STATE ... RESPONDENT
[Link].378/2013
U/S 420/34 IPC
[Link] NAGAR
FIRST APPLICATION/PETITION UNDER
SECTION 438 CR.P.C. READ WITH
SECTION 482 CR.P.C. FOR GRANT OF
ANTICIPATORY BAIL TO THE
PETITIONER.
Hon’ble Chief Justice and
His Hon’ble companion Judges
Of Hon’ble Delhi High Court.
The humble petition of the
Petitioner above named.
1. That the petitioner has been falsely
implicated in the present FIR at the
behest of compliant.
2. That the petitioner is preferring the
present petition for grant of anticipatory
bail before this Hon’ble Court on
dismissal of the bail application U/s 438
Cr.P.C. by the court of Sh. Deepak Garg,
Ld. ASJ, (North) Rohini Court Delhi vide
order dated 20.01.2014. Copy of order
dated 20.01.2014 is annexed as Annexure P-
1.
3. That the petitioner craves leave of this
Hon’ble Court to prefer the brief facts
of the case which are as under:-
B R I E F F A C T S
i) That a FIR bearing No. 378/2013, U/s
420/34 IPC, P.S. Mukherjee Nagar, Delhi
has been registered against the petitioner
and his wife. Copy of the FIR along with
its typed copy and English translation are
collectively annexed as Annexure-P-2.
ii) That the petitioner again preferred to
file on anticipatory bail after having
expert opinion of the signature of husband
of the petitioner and her husband Raj
Kumar. Copy of expert opinion the annexed
as Annexure P-3.
iii) That the complainant had filed a Civil
suit before the Hon’ble Delhi High Court
and same is pending for adjudication. Copy
of Civil suit is annexed as Annexure P-4.
iv) That as a matter no concern with the
offence and the company has wrongly filed
the complaint against the present
petitioner. Hence, the petitioner is
preferring the present petition in the
light of the fact of changed circumstances
inter-alia amongst the following grounds:-
G R O U N D S:
a. Because the Ld. ASJ has failed to
appreciate the fact that complaint as
alleged upon which the FIR No. 378/2013 has
been registered, was filed after a lapse of
a period of almost five months since the
date of the filing of the civil suit which
is pending before the Hon’ble Delhi High
Court.
b. Because the Ld. ASJ has failed to
appreciate the fact that the complainant had
not discloses the pendency of the Civil suit
which is pending against the petitioner
before Hon’ble Delhi High Court and thus the
complainant had concealed the material facts
in his compliant upon which the FIR is
registered.
c. Because the Ld. ASJ has failed to
appreciate that the expert opinion wherein
it has been opined by the expert that the
signature of the petitioner not matched with
the other signatures.
d. Because the Ld. ASJ has failed to
appreciate that the complainant has filed
forged and fabricated receipt.
e. Because the Ld. ASJ failed to
consider the fact that the complainant
allegedly stated that I got stop the payment
of cheque after seen the conduct of
petitioner herein but factually he had not
handed over cheque amounting to Rs. 16 Lacs.
f. Because from the bare perusal of the
FIR it is crystal clear that the petitioner
herein is not at all required for custodial
interrogation, thus no purpose is to be
served by arresting the petitioner in the
above noted FIR.
g. Because the contents of the FIR are
crystal clear that the petitioner has
nothing to do in commission of the alleged
offence. Thus it is clear that the
petitioner is innocent and has no nexus or
hand in the commission of alleged offence.
h. Because the petitioner has been
falsely implicated by the complainant in
order to extort the money from the
petitioner.
i. Because Ld. ASJ failed to consider
the fact that the petitioner herein he is
regularly appearing through her Counsel
before Hon’ble High Court and perusing the
civil suit which is pending against the
present petitioner.
j. Because the Ld. ASJ failed to
appreciate the fact that the present
petitioner had filed a detailed written
statement in respect of the civil suit filed
by the complainant.
k. Because the petitioner undertakes
that he will join the investigation before
the IO/SHO/Arresting Officer, as and when
required and called upon to do so.
l. Because the police officials are
constantly attempting to arrest the
petitioner without any basis, hence the
petitioner apprehending his arrest.
m. Because the petitioner is having
clean antecedent and is having deep root in
the society and has never involved in any
case.
n. Because the petitioner further
undertakes that she will not misuse the
liberty of bail in any manner whatsoever.
2. That the petitioner has not filed any
other petitioner either before this Hon’ble
court or before Supreme Court of India for
the same or similar relief.
P R A Y E R:
It is, therefore, most respectfully
prayed that:-
i) Your lordship may graciously be pleased to
pass an order for grant of anticipatory bail
to the petitioner, thereby, directing the
IO/SHO/arresting officer to release the
petitioner on bail in the event of his
arrest, in the interest of justice.
IN THE HON’BLE HIGH COURT OF DELHI AT NEW DELHI
BAIL APPLICATION NO.__________OF 2010
IN THE MATTER OF:
RAJ RANI ...PETITIONER
VERSUS
THE STATE ... RESPONDENT
A F F I D A V I T
I, Raj Rani W/o Raj Kumar @ Raju aged
about 5 years R/o [Link]. 375, Pritam
Nagar, near Tagore Model School, Ludhiana,
(Punjab) presently at Delhi, do hereby
state and declare on solemn affirmation as
under:-
1. That the deponent is the petitioner in the
above noted matter and as is well
conversant with the facts and
circumstances of the case and is competent
to swear this affidavit.
2. That the accompanying petition under
section 438 Cr.P.C. read with section 482
Cr.P.C. for grant of anticipatory bail has
been drafted by my counsel under my
instruction and the same have been
read over by me in vernacular and the same
are accepted by me as true and correct
IN THE HON’BLE HIGH COURT OF DELHI AT NEW DELHI
BAIL APPLICATION NO.__________OF 2010
IN THE MATTER OF:
RAJ RANI ...PETITIONER
VERSUS
THE STATE ... RESPONDENT
APPLICATION UNDER SECTION 482 CR.P.C. FOR
GRANT OF EXMEPTION FROM FILIG THE
CERTIFIED COPIES OF ANNEXURES ON BEHALF OF
THE PETITIONER.
MOST RESPECTFULLY SHOWETH:-
1. That the petitioner has filed the
accompanying petition under section 438
read with section 482 of the code of
criminal procedure for grant of
anticipatory bail, which is pending before
Hon’ble court for adjudication.
2. That the petitioner has filed the
annexures which are true and correct
copies of the originals. It is submitted
that the delivery of the certified copy
will take sufficient time, where as the
present matter is urgent one, hence this
application.
It is, therefore, most respectfully
prayed that this Hon’ble court may
graciously be please to exempt the
petitioners from filing the certified
copies of the annexure, in the interest of
justice.
IN THE HON’BLE HIGH COURT OF DELHI AT NEW DELHI
M.A. NO. OF 2014
IN
BAIL APPLICATION NO.__________OF 2014
IN THE MATTER OF:
RAJ RANI ...PETITIONER
VERSUS
THE STATE ... RESPONDENT
A F F I D A V I T
I, Raj Rani W/o Sh. Raj Kumar @ Raju
aged about 5 years R/o [Link]. 375, Pritam
Nagar, near Tagore Model School, Ludhiana,
(Punjab) presently at Delhi, do hereby
state and declare on solemn affirmation as
under :-
1. That the deponent is the petitioner in the
above noted matter and as such is well
conversant with the facts of the case and
is competent to swear this affidavit.
2. That the accompanying application under
section 482 Cr. P.C. has been drafted by
my counsel under my instruction and the
same have been read over by me in
vernacular and the same are accepted by me
IN THE HON’BLE HIGH COURT OF DELHI AT NEW DELHI
BAIL APPLICATION NO.__________OF 2014
IN THE MATTER OF:-
RAJ RANI ...PETITIONER
VERSUS
THE STATE ... RESPONDENT
I N D E X
[Link] Particulars Pages [Link]
1. Urgent Application
2. Memo of Parties.
3. Petition under Section Rs.3.00
438 Cr.P.C. read with
section 482 Cr.P.C.
alongwith Affidavit in
support.
4. Application U/s 482
Cr.P.C. for exemption
from filing certificate
copy of Annexures
alongwith affidavit in
support
5. Annexure P-1
Attested copy of bail
order dt. 20.01.2014
6. Annexure P-2 -
Copy of FIR and fairy
copy and its English
version.
7. Annexure P-3
Copy of expert opinion.
8. Annexure P-4
Copy of civil suit.
9. Vakalatnama
FILED BY:
DELHI
DATED: .01.2014
PAWAN SHARMA & ASSOCIATES
ADVOCATES
FIRST INFORMATION REPORT
CIPA RI 1100 (Under section 154 Cr. P.C.)
1. District- NORTH-WEST DELHI P.S.: Mukherjee Nagar Year-
2013 FIR No.378 /2013 Dated-23.09.2013
2. Act(s): Section (s)
(i) IPC 1860 U/s 420/34 IPC
(ii)
(iii)
(iv)
3. Occurrence of offence:
(a) Day: Thursday Date from: 05.01.2012 Date to:23.09.2013
Time Period: Time from: . Time to:
(b) Information received at PS: Date-23.09.2013Time- 01:30 hrs.
(c) General Diary Reference Entry No. 4A Time- 01.30 hrs.
4. Type of Information: WRITTEN
5. Place of Occurrence:
(a) Direction and distance from PS: Beat No.
(b) Address: [Link]. 167, DHAKKA VILLAGE, DELHI
(c) In case, outside the limit of this Police Station:
Name of P.S.
5. Complainant/informant
a. Name: DR. NAVEEN CHAUHAN (D/O) RISHIPAL CHAUHAN
b. Birth Year : Nationality: INDIAN
c. Passport No. Date of Issue: Place of Issue:
d. Occupation:
e. Address: [Link]. 166, DHAKKA VILLAGE, DELHI
7 Detail of known/ suspected /unknown accused, with full
particulars: (attached separate sheet if necessary)
(i) RAJ KUMAR (S/O) LATE AMAN SINGH
R/O X [Link]. 167, DHAKKA VILLAGE, DELHI
(ii) RAJ RANI (W/O) RAJ KUMAR
R/O X [Link]. 167, DHAKKA VILLAGE, DELHI
(iii)
8. Reasons for delay in reporting by the complainant/Informant. NO
DELAY
9. Particulars of properties stolen/involved (attach separate sheet if
necessary)
Sl. No. Property Type (Description) est. Values (Rs.)
status
(i)
(ii)
(iii)
10. Total value of property stolen
11. Inquest Report/U.D. case No., if any:
12.F.I.R. Contents (attach separate sheet, if
required): To, Thre S.H.O. P.S. Mukherjee
Nagar, Delhi dated 22.07.2013 Sir, I Dr.
Naveen Chauhan S/o Sh. Rishipal Chauhan
R/o [Link]. 166, Dhakka Village lving with
my family. I agree to purchase [Link]. 167,
Dhakka Village from Raj Kumar S/o Late
Aman Singh with consideration of Rs. 65
Lakhs and I gave Rs. 1 lakh cash and Rs. 2
Lakhs by cheque No. 598186 dated 3.05.2012
Bank of Baroda,, Model Town, Dehi to son
of Raj Kumar Gulshan because he said to me
that he did not have any account on his
name. So I give on the name of his son.
After that he got 2.60 Lakhs cash to me
dated on 08.05.2012 and an Agreement to
Sell & Purchase executed on my name dated
on 08.05.2012. It had decided that
remained balance of Rs. 50.40 Lakhs has to
paid on 01.05.2014 and he will execute
Sale deed on my name. Possession of 2
rooms was given to me and he promised to
me that possession of remained 3 rooms
will be given on payment. After that Raj
Kumar and his wife said to me for balance
payment and on Dec. 2012 and demanded Rs.
30 Lakhs was part payment because his son
Gulshan had to purchase house and shop at
Punjab. The I gave Rs. 15 Lakhs to Raj
Kumar and Raj Rani at their house after
arrange Rs. 12 Lakhs from my relations
with very difficulties. When I gave Rs. 27
Lakhs at that time Sumit Kumar and Titu
were present and Raj Kumar and Raj Rani
gave to receipt to me of Rs. 27 Lakhs and
they said to their tenants that you have
pay rent to Dr. Naveen Chauhan. Because I
have sold this house to Dr. Naveen Chauhan
and possession of this house has been
given to Dr. Naveen Chauhan. Aforesaid Raj
Kumar said to me for remained payment by
cheque and they will execute Sale deed on
your name. Then on his demand, I gave a
cheque No. 601396 Bank of Baroda, Model
Town, Delhi of Rs. 1 lakh on the name of
his son Gulshan and said that cheque of
Rs. 16 Lakhs has to present in the bank at
the time of Sale deed. And I will give you
7.40 Lakhs cheque by the way time is fixed
till 01.05.2014. After taking aforesaid
cheque of Rs. 27 Lakhs and Rs. 16 Lakhs
cash, Raj Kumar and his wife did not meet
me and when I tried to talk on phone to
them said for registry then they did not
give me any satisfactory answer. And after
that they stopped to receive my call on
phone. The it creates doubt in my mind and
I stopped the payment of Rs. 16 Lakhs
cheque in Bank. And after that I did not
got my information about Raj Kumar and Raj
Rani. Prem Singh jij and his friends
attacked on me, my family members and
friends with the intention for taking
possession of aforesaid House No. 167 and
after this attack I got information that
Raj Kumar and Raj Rani have transferred
the documents on the name of other after
taking Rs. 32.60 Lakhs from me and I am
cheated and they have run after taking
saving amount of me and my family members.
I have filed complaint in this regard
earlier. So strongest action may be taken
against aforesaid Raj Kumar and Raj Rani
and case of cheating may be filed against
them. I and my family will be obliged. Dr.
Naveen Chauhan S/o Sh. Rishipal Chauhan,
Chamber [Link]. 166, Dhakka Villlage near
Kingsway Camp, Delhi-8, Ph: 9811106609,
9968979762.
13. Action taken since the above report
records commission of offence (s) U/s as
mentioned as item No.2.
ii. Registered the case and took up the
investigation or.
ii. Directed/entrusted (Name of I.O.) Subhash
Chand Rank
No. 16080390 to take up the investigation
OR
iii. Refused investigation due to. OR
iv. Transferred to P.S. District
On point of jurisdiction.
F.I.R. Record over to the complainant/
informant, admitted to be correctly
records and copy given to this
complainant/informant free of cost.
R.O.A.C. Signature of officer
Name
Rank
14. Signature/Thumb impression of the
complainant/informant.
15. Date and time of dispatch to Court by DAK.
IN THE COURT OF SHRI RAJNEESH KUMAR GUPTA, ASJ-
01/WEST: DELHI
Bail Application No. 7992
State Vs. Ajay Kumar
FIR : 155/13
U/s : 498-A/406/34 IPC
PS : Punjabi Bagh
04.10.2013
Pr. : Ld. APP for the state.
Sh. Ishant Kumar advocate for the
accused.
Complainant in person with Ld. Counsel
Sh. Baljeet Kumar.
Heard on the application for
anticipatory bail. File perused.
In brief the case of the police is
that the accused along with co-accused used to
harass the complainant in connection with the
demands of dowry. The FIR has been registered
U/s 498-A/406/34 IPC.
Ld. Counsel for the accused has argued
that the accused has married with the
complainant on 12.11.2003. The accused has not
made any demands of dowry and has not harassed
the complainant in any way. The accused is
ready to join the investigation as and when
required by the IO. on these grounds, it is
prayed that the accused be granted to
anticipatory bail.
On the other hand, Ld. APP for the state
has argued that the allegations against the
accused are serious in nature and so he is not
entitled to anticipatory bail.
Report of IO perused. As per report, the
accused has never joined the investigation in
this case. The accused is the husband of the
complainant. Keeping in view the seriousness of
the allegations against the accused, I am of
the opinion that the release of accused Ajay
Kumar on anticipatory bail would affect the
investigation of the case and so he is not
entitled to anticipatory bail. Accordingly,
application of Ajay Kumar for anticipatory
bail.
Sd/-
(Rajneesh Kumar Gupta)
ASJ-01(West)
04.10.13
